Subject: File No. S7-24-15
From: Kenneth Church

April 7, 2020

I am against this proposal. I believe that the existing regulations are entirely sufficient and appropriate. As it is, the more risk averse are likely dissuaded from using these vehicles, to their detriment. I have used these instruments, both ProShares and Direxion for years, and have found them to be among the very best instruments available in the marketplace. I use them in many different ways, for example hedging, as a better alternative to options and margin borrowing, to shift my asset allocations quickly, to get better exposure to the foreign markets, to shift from long to short quickly and vice versa and many others. They have also been consistently profitable for me in total. They have generally constituted 2.5-5% of my total portfolio. They also provide me with access to alternative asset classes, through ProShares Trust II, such as currencies and precious metals. The SEC should declare victory and move on to something they really need to do such as putting an end to the abusive and detrimental mutual fund 12-b1 fees, which should have never been approved in the first place